Outcome: The civil appeal was dismissed, while time was granted to the appellant to file a response to the show-cause notice.

Issues: Whether the appellant, having remained in custody for a substantial period after filing of the prosecution complaint, was entitled to bail notwithstanding the restrictions under Section 45 of the Prevention of Money Laundering Act, 2002.

Analysis: The prosecution complaint had already been filed, the appellant had remained in custody for over eight months, and he had earlier appeared before the Enforcement Directorate on several occasions. In these circumstances, further detention pending trial was not considered necessary. The restrictions in Section 45 of the Prevention of Money Laundering Act, 2002 cannot be used to justify indefinite detention, and the twin conditions therein must yield to the constitutional protection of personal liberty under Article 21 of the Constitution of India in appropriate cases.

Conclusion: The appellant was held entitled to bail, subject to terms and conditions to be fixed by the trial court.

Ratio Decidendi: The twin conditions for bail under the Prevention of Money Laundering Act, 2002 cannot override Article 21 where continued custody is unnecessary and the case otherwise warrants release on bail.

Issues: (i) Whether secured creditors have priority over property attached under the prevention of money laundering regime by reason of the recovery statutes; (ii) whether property provisionally attached and confirmed as proceeds of crime can be released in favour of a secured creditor claiming statutory priority; (iii) whether the appellate tribunal was right in setting aside the attachment on the footing that the recovery statutes prevailed.

Issue (i): Whether secured creditors have priority over property attached under the prevention of money laundering regime by reason of the recovery statutes.

Analysis: The competing enactments operate in different fields. The money laundering statute is a confiscatory law directed against proceeds of crime and contains an overriding clause. The recovery statutes are designed to enable banks and secured creditors to realise debts and security interests. Their priority clauses cannot be read as displacing the confiscatory scheme of the money laundering law. The two statutory schemes must be reconciled, not collapsed into one another.

Conclusion: The secured creditor does not get automatic priority over property attached under the money laundering statute merely because of the recovery statutes.

Issue (ii): Whether property provisionally attached and confirmed as proceeds of crime can be released in favour of a secured creditor claiming statutory priority.

Analysis: An order of attachment under the money laundering statute is not rendered invalid simply because a secured creditor has a prior mortgage or charge. At the same time, a prior attachment does not ipso facto extinguish a bona fide third party's claim. The statute itself provides a mechanism for restoration before the Special Court. Once attachment is confirmed and the criminal proceedings are underway, the appropriate forum to seek release or restoration is the Special Court under the restoration provision.

Conclusion: The attached property cannot be released merely on the basis of secured creditor status, though the creditor may seek appropriate relief before the Special Court.

Issue (iii): Whether the appellate tribunal was right in setting aside the attachment on the footing that the recovery statutes prevailed.

Analysis: The appellate tribunal proceeded on an incorrect assumption that the recovery statutes override the money laundering statute. That approach ignored the distinct objects of the enactments and the controlling effect of the money laundering law in relation to proceeds of crime. The tribunal also did not furnish a sustainable basis for nullifying the attachment order on the facts before it.

Conclusion: The tribunal's order setting aside the attachment was unsustainable.

Final Conclusion: The appeals were allowed, the tribunal's orders were quashed, and the attachment stood restored without prejudice to the secured creditor's right to pursue restoration before the Special Court.

Ratio Decidendi: A statutory priority given to secured creditors under recovery laws does not override attachment and confiscation under the money laundering statute; the latter prevails for proceeds of crime, while bona fide third-party claims must be pursued before the Special Court under the restoration mechanism.

Issues: Whether the amount deposited during investigation was a voluntary duty payment or a deposit made under a mistaken notion at the department's insistence, and whether interest at 12% per annum was payable on the refunded amount from the date of deposit till the date of refund.

Analysis: The amount of Rs. 20,00,000/- was deposited during investigation pursuant to departmental insistence after search proceedings, and the records showed that it was not a voluntary discharge of excise duty. Such payment was treated as an amount paid under a mistaken notion regarding duty liability, not as a pre-deposit made voluntarily under Section 35F of the Central Excise Act, 1944. On that footing, Section 11B of the Central Excise Act, 1944 was held inapplicable to deny interest, and the reasoning adopted in the earlier tribunal decision allowing interest on investigation-stage deposits was followed. The claim for interest was also supported by the view that refund of such amount must carry interest automatically when the assessee succeeds.

Conclusion: The deposit was not a voluntary duty payment and the assessee was entitled to interest at 12% per annum from the date of deposit till the date of refund.

Issues: (i) Whether the additions made on the basis of alleged clandestine sales and related unexplained investment could be sustained after the underlying allegation was found unsustainable.

Issue (i): Whether the additions made on the basis of alleged clandestine sales and related unexplained investment could be sustained after the underlying allegation was found unsustainable.

Analysis: The additions were founded on the premise that the assessee had made suppressed sales and had introduced unaccounted capital/investment. The Tribunal noted that the principal allegation of clandestine removal, on which the estimation of gross profit and unexplained investment was based, had not been sustained in the related excise proceedings. In that background, the factual foundation for the impugned additions was held to be absent, and the assessment additions could not stand independently.

Conclusion: The additions were not sustainable and were deleted.

Final Conclusion: The assessee's challenge succeeded in full, and the assessment additions confirmed in appeal were set aside.

Issues: Whether a consolidated satisfaction note recorded under section 153C of the Income-tax Act, 1961 for multiple assessment years vitiates the proceedings and the consequential assessment.

Analysis: The assessee challenged the validity of the proceedings on the ground that the Assessing Officer of the searched person and the Assessing Officer of the assessee had recorded combined satisfaction notes for several assessment years instead of year-wise satisfaction. The Tribunal noted that the satisfaction notes covered multiple years in one composite exercise and relied on the view that satisfaction under section 153C must be recorded separately for each assessment year because jurisdiction under that provision is assessment-year specific. On that basis, the Tribunal held that a consolidated satisfaction note is not in accordance with law and affects the very assumption of jurisdiction for proceedings under section 153C.

Conclusion: The consolidated satisfaction note invalidated the section 153C proceedings, and the assessee succeeded on the legal challenge.

Ratio Decidendi: For proceedings under section 153C of the Income-tax Act, 1961, satisfaction must be recorded separately for each assessment year, and a consolidated satisfaction note for multiple years is fatal to the assumption of jurisdiction and the resulting assessment.

Issues: (i) Whether interest earned by a co-operative society from deposits made with co-operative banks is eligible for deduction under section 80P(2)(d) of the Income-tax Act, 1961.

Analysis: The interest income arose from investments of surplus funds placed with co-operative banks. The legal question turned on whether such receipts fell within the expression income by way of interest derived by the co-operative society from its investments with any other co-operative society. The Tribunal followed the most recent binding and persuasive authorities, including the decision of the jurisdictional High Court and the later High Court view holding that section 80P(2)(d) applies to interest earned from co-operative banks and that the exclusion in section 80P(4) is directed to co-operative banks claiming deduction, not to a co-operative society earning interest from such banks. The contrary view was not accepted in preference to the authorities relied upon for the assessee.

Conclusion: The assessee is entitled to deduction under section 80P(2)(d) on the interest earned from deposits with co-operative banks, and the disallowance was unsustainable.

Ratio Decidendi: For a co-operative society, interest derived from deposits with a co-operative bank qualifies for deduction under section 80P(2)(d) where the receiving entity is treated as a co-operative society for that purpose, and section 80P(4) does not deny the deduction to the investing co-operative society.

Issues: (i) Whether the recovery of customs duty, confiscation and penalties under Section 28AAA of the Customs Act, 1962 were valid where the SEIS scrips had been obtained on a mis-declaration of the nature of services and had already been cancelled by the DGFT; (ii) Whether the penalty imposed on the Chief Financial Officer under Sections 112(a) and 114AA of the Customs Act, 1962 was sustainable.

Issue (i): Whether the recovery of customs duty, confiscation and penalties under Section 28AAA of the Customs Act, 1962 were valid where the SEIS scrips had been obtained on a mis-declaration of the nature of services and had already been cancelled by the DGFT.

Analysis: Section 28AAA applies where an instrument is obtained by collusion, wilful misstatement or suppression of facts and is later utilised by a person other than the issuee. The SEIS framework under the Foreign Trade policy permitted duty credit scrips for notified services only, and the record showed that the services were wrongly declared as eligible consulting services though they were IT/ITES services not covered by the notified list. The DGFT had already cancelled the scrips void ab initio after investigation, which established that the instrument had been wrongly obtained. Once the cancellation stood unchallenged, customs authorities were competent to recover the duty relatable to utilisation of the scrips and to sustain confiscation and penalties for the deliberate mis-declaration.

Conclusion: The invocation of Section 28AAA, the duty demand, confiscation under Sections 111(m) and 111(o), and the penalties on the company were upheld.

Issue (ii): Whether the penalty imposed on the Chief Financial Officer under Sections 112(a) and 114AA of the Customs Act, 1962 was sustainable.

Analysis: The Chief Financial Officer's statement had admitted ineligibility for SEIS benefit and the duty had been voluntarily paid with interest. The role attributed to him was that of an employee acting under the company's directions, and the company itself had already been penalised. On these facts, separate penal liability on him was not justified.

Conclusion: The penalty imposed on the Chief Financial Officer was set aside.

Final Conclusion: The customs demand and consequential action were sustained against the company, while the personal penalty on the Chief Financial Officer was deleted, resulting in partial relief to the assessee side.

Ratio Decidendi: When a duty credit scrip is procured by wilful misstatement or suppression of facts and the competent FTDR authority has already cancelled it as void ab initio, customs recovery under Section 28AAA is maintainable; however, a separate penalty on an individual employee is unsustainable absent an independent basis for personal culpability.

Issues: (i) whether the reply dated 15.06.2022 to the demand notice constituted a notice of dispute under the Insolvency and Bankruptcy Code, 2016; (ii) whether the defence raised by the corporate debtor in that reply and in its response to the section 9 application was spurious or moonshine; (iii) whether the GST assessment order dated 02.07.2025 was relevant and supported the corporate debtor's case.

Issue (i): whether the reply dated 15.06.2022 to the demand notice constituted a notice of dispute under the Insolvency and Bankruptcy Code, 2016.

Analysis: Section 8 requires the corporate debtor, upon receipt of a demand notice, to bring to the operational creditor's notice the existence of a dispute. Section 9(1) permits initiation of CIRP only if payment is not received and no notice of dispute is received, while section 9(5)(ii)(d) mandates rejection where a notice of dispute has been received. The reply dated 15.06.2022 specifically disputed the invoices, alleged non-supply, fake invoices, return of materials, and audit/investigation preceding the notice, thereby raising a pre-existing controversy.

Conclusion: The reply dated 15.06.2022 was a notice of dispute within section 9(5) of the Insolvency and Bankruptcy Code, 2016.

Issue (ii): whether the defence raised by the corporate debtor in that reply and in its response to the section 9 application was spurious or moonshine.

Analysis: The applicable test is whether the dispute is a plausible contention requiring further investigation and not a patently feeble, hypothetical, or illusory plea. The materials relied upon included the internal audit commenced in December 2021, the contemporaneous email admitting rejection/return of certain goods, the absence of post-December 2021 payments to the operational creditor, and the detailed invoice-wise denial in the section 9 reply. These circumstances showed a real dispute existing before the demand notice and not a mere bluster.

Conclusion: The defence was not spurious or moonshine, and the section 9 application ought to have been rejected under section 9(5)(ii)(d) of the Insolvency and Bankruptcy Code, 2016.

Issue (iii): whether the GST assessment order dated 02.07.2025 was relevant and supported the corporate debtor's case.

Analysis: The assessment order was taken on record and addressed e-way bill movement, procurement source, duplicate invoices, and invoices raised without actual supply of goods. It recorded that several invoices lacked vehicle movement, some invoices were duplicates or replicas, and no input tax credit was claimed for certain invoices in the recipient's GST returns. These findings directly aligned with the corporate debtor's stand that the invoices were fictitious or unsupported by supply.

Conclusion: The GST assessment order dated 02.07.2025 was relevant and supported the corporate debtor's defence.

Final Conclusion: The admission order under section 9 could not be sustained because a pre-existing dispute was established on the record, and the operational creditor's insolvency application was liable to be rejected.

Ratio Decidendi: An operational creditor's section 9 application must be rejected where, before the demand notice, the corporate debtor raises a real and plausible dispute supported by material, and subsequent adjudicatory material may corroborate that the dispute was not spurious or illusory.

Issues: Whether the intra-court appeals against the reasoned order of the learned Single Judge merited admission and interference.

Analysis: The appeals arose from a common order in which the learned Single Judge had dealt with the availability of a statutory appellate remedy, the plea of limitation, and the alleged breach of natural justice in the context of notices issued under the VAT regime. The appellate Court found that the impugned order was a reasoned one, that the learned Single Judge had considered the material questions raised, and that the scope of interference in intra-court appeal was limited. On that basis, the Court declined to reopen the controversy at the admission stage.

Conclusion: The appeals were not admitted and no interference was warranted; the challenge failed.

Final Conclusion: The judgment leaves the learned Single Judge's disposal undisturbed and results in dismissal of the batch of intra-court appeals.

Ratio Decidendi: A reasoned order declining writ interference in the presence of an alternative statutory remedy will ordinarily not be interfered with in intra-court appeal unless a clear jurisdictional or legal infirmity is shown.

Issues: (i) whether supplies made by a Domestic Tariff Area unit to a unit in a Special Economic Zone constituted deemed exports under the Foreign Trade Policy so as to permit discharge of EPCG export obligation by supply invoices and bank realisation certificates; (ii) whether the Special Economic Zones Act, 2005 and the Special Economic Zones Rules, 2006 displaced the Foreign Trade Policy and required a Bill of Export as the only proof of export obligation discharge.

Issue (i): whether supplies made by a Domestic Tariff Area unit to a unit in a Special Economic Zone constituted deemed exports under the Foreign Trade Policy so as to permit discharge of EPCG export obligation by supply invoices and bank realisation certificates.

Analysis: Paragraph 8.1 of the Foreign Trade Policy defines deemed exports as transactions in which the goods supplied do not leave the country and payment is received in Indian rupees or free foreign exchange. Paragraph 8.2 lists recognised categories of deemed export, but it is not exhaustive of every supply that answers the broader definition in paragraph 8.1. Supplies to a Special Economic Zone unit remain supplies within India and can satisfy the definition of deemed exports when the payment condition is met. The supply invoices and bank realisation certificates therefore constituted adequate proof of discharge of the export obligation.

Conclusion: The issue is answered in favour of the respondent. The supplies were deemed exports and did not require treatment as physical exports for EPCG redemption.

Issue (ii): whether the Special Economic Zones Act, 2005 and the Special Economic Zones Rules, 2006 displaced the Foreign Trade Policy and required a Bill of Export as the only proof of export obligation discharge.

Analysis: Section 2(m)(ii), Section 51 and Section 53(1) of the Special Economic Zones Act, 2005 operate within the statutory field of the SEZ regime and the legal fiction in Section 53(1) is confined to the purpose for which it is created, namely authorised operations. That fiction cannot be extended to rewrite the EPCG scheme under the Foreign Trade Policy and Handbook of Procedures. Rule 23 of the Special Economic Zones Rules, 2006 recognises export benefits for supplies from the Domestic Tariff Area, and Rule 30 regulates admission and proof within the SEZ framework, but those provisions do not override the export incentive regime governing EPCG redemption. The later DGFT policy relaxation also reinforced that insistence on a Bill of Export was not indispensable where other corroborative evidence existed.

Conclusion: The issue is answered in favour of the respondent. The SEZ provisions did not override the Foreign Trade Policy so as to make a Bill of Export the exclusive proof of fulfilment of export obligation.

Final Conclusion: The review failed because no error apparent on the face of the record was shown in the earlier decision holding that the EPCG obligation could be discharged on the basis of deemed exports supported by supply invoices and bank realisation certificates.

Ratio Decidendi: A statutory deeming fiction is confined to the purpose for which it is created, and where the foreign trade scheme itself treats in-country supplies as deemed exports, compliance may be proved by the documents recognised under that scheme rather than by insisting on a Bill of Export unless the governing law clearly makes it indispensable.

Issues: (i) Whether the appellant correctly applied Rule 6(3A) while computing proportionate reversal, including treatment of common credit and inclusion of electricity and trading turnover. (ii) Whether the impugned orders travelled beyond the scope of the Show Cause Notices. (iii) Whether the extended period of limitation was invocable. (iv) Whether the penalties were sustainable.

Issue (i): Whether the appellant correctly applied Rule 6(3A) while computing proportionate reversal, including treatment of common credit and inclusion of electricity and trading turnover.

Analysis: Rule 6 requires reversal only of credit attributable to exempted output and does not permit loading of credit exclusively relatable to dutiable clearances into the apportionment formula. Rule 6(3A) is a quantification mechanism for common credit and cannot be used to deny otherwise admissible credit. The appellant had reversed proportionate common credit, and the value of electricity and trading turnover was relevant only for the computation under the formula. The demand based on inclusion of exclusive credit and substitution of the appellant's chosen option was inconsistent with the statutory scheme.

Conclusion: The appellant correctly applied Rule 6(3A), and the demand on this ground was unsustainable.

Issue (ii): Whether the impugned orders travelled beyond the scope of the Show Cause Notices.

Analysis: Adjudication is confined to the allegations made in the Show Cause Notice. The notices alleged short reversal under Rule 6(3A), but the orders proceeded on a broader footing by reworking liability on an alternative basis and by introducing grounds not specifically alleged. A confirmation on a foundation not put to notice enlarges the case beyond the notice.

Conclusion: The impugned orders travelled beyond the Show Cause Notices to the extent indicated and were unsustainable.

Issue (iii): Whether the extended period of limitation was invocable.

Analysis: The dispute arose from disclosed records and audit scrutiny and turned on interpretation of the Rule 6(3A) formula. The facts were reflected in returns and statutory records, and there was no material showing fraud, collusion, wilful misstatement, suppression of facts, or intent to evade duty. In a purely interpretational dispute with full disclosure, the extended period cannot be invoked.

Conclusion: The extended period of limitation was not invocable.

Issue (iv): Whether the penalties were sustainable.

Analysis: Penalty under Rule 15(2) read with Section 11AC requires the element of fraud, wilful misstatement, suppression, or analogous mens rea. Since the dispute was interpretational, based on disclosed records, and the demand itself was not sustainable, the preconditions for penalty were absent.

Conclusion: The penalties were not sustainable.

Final Conclusion: The orders confirming duty, interest, and penalties were set aside and the appeals succeeded with consequential relief.

Ratio Decidendi: Rule 6(3A) permits reversal only of common credit attributable to exempted output, adjudication cannot exceed the allegations in the Show Cause Notice, and extended limitation and penalty are unavailable in the absence of suppression or other culpable conduct in a disclosed interpretational dispute.

Issues: Whether income-tax assessments completed after approval of an insolvency resolution plan were liable to be quashed.

Analysis: The applicable authority gives an approved resolution plan overriding effect under the Insolvency and Bankruptcy Code, 2016. Approval freezes creditor liabilities and extinguishes claims not included in the plan. The precedent concerning statutory demands had been distinguished in the decisions followed.

Conclusion: The assessments were liable to be quashed, in favour of the assessee.

Ratio Decidendi: Approval of an insolvency resolution plan freezes creditor liabilities and extinguishes claims that do not form part of the plan.

Issues: Whether a resident individual having total income within the prescribed threshold for assessment year 2024-25 is entitled to rebate under section 87A where the total income includes capital gains chargeable at special rates.

Analysis: Section 87A grants rebate with reference to tax computed on total income and, as applicable for assessment year 2024-25, contains no exclusion for income taxable at special rates. Section 115BAC(1A) regulates the concessional tax regime and computation of rates but does not restrict the independent rebate available under section 87A. The subsequent statutory restriction on rebate for special-rate income operates prospectively and cannot govern the relevant assessment year.

Conclusion: The assessee is entitled to rebate under section 87A of the Income-tax Act, 1961 on the tax liability, notwithstanding inclusion of capital gains taxable at special rates.

Issues: Whether a notice for reassessment issued after three years from the end of the relevant assessment year was valid where approval was obtained from the Principal Commissioner rather than the Principal Chief Commissioner.

Analysis: The statutory authority competent to approve issuance of the reassessment notice is determined with reference to the date of that notice. Approval for the earlier show-cause notice does not substitute the separate sanction required for the reassessment notice and consequential order. As the reassessment notice was issued after expiry of three years, approval of the authority prescribed for that period was mandatory.

Conclusion: The reassessment notice issued with approval of the Principal Commissioner, instead of the Principal Chief Commissioner, was invalid; the assessment founded upon it was liable to be quashed, in favour of the assessee.

Issues: Whether a resident individual opting for the new tax regime and having total income within the statutory threshold is entitled to rebate under section 87A of the Income-tax Act, 1961 against tax payable on short-term capital gains taxable under section 111A for Assessment Year 2024-25.

Analysis: The Tribunal followed the coordinate bench view that the amended first proviso to section 87A applicable from Assessment Year 2024-25 grants rebate to a resident individual whose total income does not exceed the prescribed limit and who is assessed under section 115BAC(1A). It held that neither section 87A nor section 111A contains any express exclusion denying rebate in respect of tax on short-term capital gains, unlike section 112A(6), where the legislature has specifically restricted the rebate. The subsequent amendment introduced from Assessment Year 2026-27 was treated as prospective and not governing the year under appeal.

Conclusion: The assessee was held entitled to rebate under section 87A for Assessment Year 2024-25 even though the income included short-term capital gains taxable under section 111A.

Issues: (i) Whether an assessment order issued without the assessing officer's signature is valid in law; (ii) whether non-mention of a Document Identification Number affects the validity of proceedings under the GST law; (iii) whether delay in approaching the Court could defeat the challenge when the unsigned order is not duly served.

Issue (i): Whether an assessment order issued without the assessing officer's signature is valid in law.

Analysis: The absence of signature on the assessment order was treated as a substantive defect. The earlier decisions relied upon held that the signature requirement cannot be dispensed with and that the saving provisions governing irregularities in notice or order do not cure such a defect. Rule 26(3) was also noted for the proposition that service of an unsigned notice or order is no service in law.

Conclusion: An assessment order issued without the assessing officer's signature is invalid.

Issue (ii): Whether non-mention of a Document Identification Number affects the validity of proceedings under the GST law.

Analysis: The judgment followed the view that a DIN is an essential requirement for the validity of GST proceedings, as reflected in the Supreme Court's ruling and the CBIC circular. Non-inclusion of the DIN was treated as a defect going to the validity of the order itself.

Conclusion: An order under the GST law without a DIN is invalid.

Issue (iii): Whether delay in approaching the Court could defeat the challenge when the unsigned order is not duly served.

Analysis: Although the writ petition was filed belatedly, the Court held that an unsigned order cannot be treated as duly served. Since there was no valid service, the delay was not treated as a decisive factor against the challenge.

Conclusion: The delay did not bar relief.

Final Conclusion: The impugned assessment order was set aside, and the assessing authority was permitted to pass a fresh order after due notice and proper signature, with the period indicated by the Court excluded for limitation purposes.

Ratio Decidendi: In GST proceedings, an unsigned assessment order and an order lacking a DIN are invalid, and an unsigned order cannot be treated as duly served for the purpose of defeating a challenge on delay.

Issues: (i) Whether reassessment after a completed scrutiny assessment of share capital and investment transactions was impermissible as a change of opinion; (ii) Whether the reassessment notice dated 30.07.2022 was barred by limitation and, alternatively, unsupported by sanction of the competent specified authority.

Issue (i): Whether reassessment after a completed scrutiny assessment of share capital and investment transactions was impermissible as a change of opinion.

Analysis: The original assessment under Section 143(3) followed scrutiny specifically directed to share capital, investments, advances and loans. The relevant transactions were subjected to detailed enquiry and no addition was made. Reopening on the basis of an anonymous complaint, without any failure to disclose material facts or fresh tangible material, amounted to revisiting an issue already adjudicated.

Conclusion: The reassessment initiation was an impermissible change of opinion and was in favour of the assessee.

Issue (ii): Whether the reassessment notice dated 30.07.2022 was barred by limitation and, alternatively, unsupported by sanction of the competent specified authority.

Analysis: The three-year limitation for the relevant assessment year, extended under the relaxation legislation up to 30.06.2021, left only sixteen days after the original notice dated 14.06.2021. Upon application of the statutory exclusions and deemed-stay period applicable to the converted show-cause notice, the residual period expired on 21.06.2022. The notice dated 30.07.2022 was therefore beyond the available period. The proceedings had throughout proceeded on the three-year limitation basis; the conditions for invoking the extended limitation were neither recorded nor satisfied. Further, if the extended period were invoked, sanction from the Principal Commissioner was not sanction from the authority required after three years.

Conclusion: The notice dated 30.07.2022 was time-barred; alternatively, any attempted invocation of the extended period lacked sanction from the competent authority. The finding is in favour of the assessee.

Final Conclusion: The foundational reassessment notice being void ab initio, all proceedings and instruments founded upon it, including the subsequent order, notice and assessment, lacked legal validity; fresh action was left open only if otherwise permissible in law.

Ratio Decidendi: Reassessment cannot reopen transactions fully scrutinised in the original assessment merely on a change of opinion, and a converted reassessment notice must be completed within the surviving limitation period with sanction from the statutorily competent authority.